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Elevation Prep Privacy Policy (Kindly prepared pro bono by our partners at Yale Law School)

 

Elevation Prep LLC, a Delaware limited liability company (“Elevation Prep”, “we”, “our”, or “us”), respects your privacy and is strongly committed to keeping secure any information we obtain from you or about you. This Privacy Policy describes our practices with respect to Personal Information we collect from or about you when you use our website, applications, and services, including the AI Services and any other Services (each as defined in our Terms of Service), (collectively, “EP Services”).  You agree to these practices and authorize and permit us to engage in the practices and uses, and make the disclosures, each as set forth below with respect to information and other content relating to you.

 

1. Personal information we collect

We collect personal information relating to you (“Personal Information”) as follows:

 

Personal Information You Provide: We collect Personal Information as follows if you create an account to use our EP Services, use our EP Services, or communicate with us:

  • Account Information: When you create an account with us, we will collect information associated with your account, including your name, contact information, account credentials, payment card information, and transaction history, (collectively, “Account Information”).

  • College Admission Information:  Information about the colleges or other educational programs or courses of study that you plan to apply to or have applied to and acceptance and denials of your applications for admission (“collectively, College Admission Information”). You agree to provide us with College Admission Information upon our request with respect to any colleges or other educational programs or courses of study with respect to which you used our EP Services to prepare an application for admission. 

  • User Content: When you use our EP Services, we collect Personal Information that is included in the User Input (as defined in our Terms of Service), including any file uploads, or any feedback that you provide to our EP Services (“User Content”). 

  • Communication Information: If you communicate with us, we collect your name, contact information, and the contents of any messages you send (“Communication Information”).

  • Social Media Information: We have or may create pages on social media sites like Instagram, Facebook, Medium, Twitter, YouTube, and LinkedIn. When you interact with our social media pages, we will collect Personal Information that you elect to provide to us, such as your contact details (collectively, “Social Information”). In addition, the companies that host our social media pages may provide us with aggregate information and analytics about our social media activity.

  • Other Information You Provide: We collect other information that you may provide to us, such as when you participate in our events or surveys or provide us with information to establish your identity (collectively, “Other Information You Provide”).

 

Personal Information We Receive Automatically from Your Use of the EP Services: When you visit, use, or interact with the EP Services, we receive the following information about your visit, use, or interactions (“Technical Information”):

  • Log Data: Information that your browser or device automatically sends when you use our EP Services. Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interact with our EP Services.

  • Usage Data: We may automatically collect information about your use of the EP Services, such as the types of content that you view or engage with, the features you use, and the actions you take, as well as your time zone, country, the dates and times of access, user agent and version, type of computer or mobile device, and your computer connection.

  • Device Information: Includes name of the device, operating system, device identifiers, and browser you are using. Information collected may depend on the type of device you use and its settings.

  • Cookies: We use cookies to operate and administer our EP Services and to improve your experience. A “cookie” is a piece of information sent to your browser by a website you visit. You can set your browser to accept all cookies, to reject all cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it. However, refusing a cookie may in some cases preclude you from using, or negatively affect the display or function of, a website or certain areas or features of a website. Analytics: We may use a variety of online analytics products that use cookies to help us analyze how users use our EP Services and enhance your experience when you use the EP Services.

 

2. How we use Personal Information

We may use Personal Information for the following purposes:

  • To provide the EP Services and generating Output (as defined in our Terms of Service);

  • To administer, maintain, and/or analyze the EP Services;

  • To improve the EP Services and conduct research;

  • To communicate with you, including to send you information about our EP Services;

  • To communicate with your high school counsellor if you provided their contact information, including sharing information about you, including your name and high school affiliation, information about your college essay, all drafts of your college essay, all advice you received from us in connection with our essay coaching service, and all other admissions guidance we provide, including through our AI Services;

  • To develop new programs, products, and/or services;

  • To prevent fraud, criminal activity, or misuses of our EP Services, and to protect the security of our IT systems, architecture, and networks;

  • To manage payments for the EP Services;

  • To prepare for or carry out Transactions (as defined below); and

  • To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

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We may aggregate or de-identify Personal Information so that it may no longer be used to identify you and use such information to analyze the effectiveness of our EP Services, to improve and add features or new services to our EP Services, to train our artificial intelligence models as part of our Elevation Prep Technology (as defined in our Terms of Service), to conduct research, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our EP Services and share aggregated information like general user statistics with high schools, colleges, universities, or other third parties, publish such aggregated information, or make such aggregated information generally available. We may collect aggregated information through the EP Services, through cookies, and through other means described in this Privacy Policy.

As noted above, we may use User Content you provide us to improve our EP Services, for example to develop or train the artificial intelligence models that power our EP Services, including our AI Services (as defined in our Terms of Service).

 

3. Disclosure of Personal Information

In certain circumstances we may provide your Personal Information to third parties without further notice to you, unless required by applicable law:

  • Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may provide Personal Information to vendors and service providers, including providers of hosting services, customer service vendors, cloud services, email communication software, providers of artificial intelligence technology or applications thereof, web analytics services, and other information technology providers, among others. Pursuant to our instructions, these parties will access, process, or store Personal Information only in the course of performing their duties to us.

  • School Counselors: To communicate with your high school counsellor if you provided their contact information, we may share information with them about you, including your name and high school affiliation, College Admission Information, information about your college essay, all drafts of your college essay, all advice you received from us in connection with our essay coaching service, and all other admissions guidance we provide, including through our artificial intelligence technology.

  • Business Transfers: If we are involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of service to another provider (collectively, a “Transaction”), your Personal Information and other information may be disclosed in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.

  • Legal Requirements: We may share your Personal Information, including information about your interaction with our EP Services, with government authorities, industry peers, or other third parties (i) if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation, (ii) to protect and defend our rights or property, (iii) if we determine, in our sole discretion, that there is a violation of our terms, policies, or the law; (iv) to detect or prevent fraud or other illegal activity; (v) to protect the safety, security, and integrity of our products, employees, or users, or the public, or (vi) to protect against legal liability.

  • Affiliates: We may disclose Personal Information to our affiliates, meaning a person or entity that controls, is controlled by, or is under common control with Elevation Prep. Our affiliates may use the Personal Information we share in a manner consistent with this Privacy Policy.

  • Account Administrators: When you create an Elevation Prep account and while you maintain such an account, the administrators of that account may access and control your Elevation Prep account. In addition, if you create an account using an email address belonging to your high school or another organization, we may share the fact that you have an Elevation Prep account and certain account information, such as your email address, with your high school or organization to, for example, enable you to be added to their business account.

  • Other Users and Third Parties You Share Information With: Certain features allow you to display or share information with other users or third parties. For example, you may share chatbot conversations with other users via shared links or send information to third-party applications. Be sure you trust any user or third party with whom you share information.

 

4. Your rights

Depending on location, individuals may have certain statutory rights in relation to their Personal Information. For example, you may have the right to:

 

  • Access your Personal Information and information relating to how it is processed;

  • Have your Personal Information deleted from our records;

  • Rectify or update your Personal Information;

  • Transfer your Personal Information to a third party (right to data portability);

  • Restrict how we process your Personal Information;

  • Withdraw your consent—where we rely on consent as the legal basis for processing at any time; 

  • Object to how we process your Personal Information; and/or

  • Lodge a complaint with your local data protection authority.

 

You can exercise some of these rights through your Elevation Prep account. If you are unable to exercise your rights through your account, please submit your request to our customer service at team@medprepai.com.

 

 

5. Additional U.S. state disclosures

The following table provides additional information about the categories of Personal Information we collect and how we disclose that information.

 

Category of Personal Information

Disclosure of Personal Information

Identifiers, such as your name, contact details, IP address, and other device identifiers

We may disclose this information to our affiliates, vendors, and service providers to process in accordance with our instructions; to law enforcement and other third parties for the legal reasons described above; to parties involved in Transactions; to corporate administrators of enterprise or team accounts; and to other users and third parties you choose to share it with.

Commercial Information, such as your transaction history

We may disclose this information to our affiliates, vendors, and service providers to process in accordance with our instructions; to law enforcement and other third parties for the legal reasons described above; to parties involved in Transactions; and to corporate administrators of enterprise or team accounts.

Network Activity Information, such as User Content and how you interact with our EP Services

We may disclose this information to our affiliates, vendors and service providers to process in accordance with our instructions; to law enforcement and other third parties for the legal reasons described above; to parties involved in Transactions; and to other users and third parties you choose to share it with.

Geolocation Data

We may disclose this information to our affiliates, vendors and service providers to process in accordance with our instructions; to law enforcement and other third parties for the legal reasons described above; and to parties involved in Transactions.

Your account login credentials and payment card information (Sensitive Personal Information)

We disclose this information to our affiliates, vendors and service providers, law enforcement, and parties involved in Transactions.

 

 

You can read more about the Personal Information we collect in “Personal information we collect” above, how we use Personal Information in “How we use personal information” above, and how we retain Personal Information in “Security and Retention” below.

To the extent provided for by local law and subject to applicable exceptions, individuals may have the following privacy rights in relation to their Personal Information:

  • The right to know information about our processing of your Personal Information, including the specific pieces of Personal Information that we have collected from you;

  • The right to request deletion of your Personal Information;

  • The right to correct your Personal Information; and

  • The right to be free from discrimination relating to the exercise of any of your privacy rights.

We don’t “sell” Personal Information or “share” Personal Information for cross-contextual behavioral advertising (as those terms are defined under applicable local law). We also don’t process sensitive Personal Information for the purposes of inferring characteristics about a consumer.

Exercising Your Rights. To the extent applicable under local law, you can exercise privacy rights described in this section by submitting a request through our customer service at team@medprepai.com.

Verification. In order to protect your Personal Information from unauthorized access, change, or deletion, we may require you to verify your credentials before you can submit a request to know, correct, or delete Personal Information. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Information and proof of residency for verification. If we cannot verify your identity, we will not be able to honor your request.

Authorized Agents. You may also submit a rights request through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity and submit proof of your residency with us. Authorized agent requests can be submitted to our customer service at team@medprepai.com.

Appeals. Depending on where you live, you may have the right to appeal a decision we make relating to requests to exercise your rights under applicable local law. To appeal a decision, please send your request to our customer service at team@medprepai.com.

 

6. Children

Our EP Services are not directed to children under the age of 16. Elevation Prep does not knowingly collect Personal Information from children under the age of 16. If you have reason to believe that a child under the age of 16 has provided Personal Information to Elevation Prep through the EP Services, please email us at our customer service at team@medprepai.com. We will investigate any notification and if appropriate, delete the Personal Information from our systems. If you are 13 or older, but under 18, you must have permission from your parent or guardian to use our EP Services.

 

7. Links to other websites

The EP Services may contain links to other websites not operated or controlled by Elevation Prep, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

 

8. Security and Retention

We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the EP Services or email. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the EP Services, or third-party websites.

We’ll retain your Personal Information for only as long as we need in order to provide our EP Services to you, or for other legitimate business purposes such as resolving disputes, safety and security reasons, or complying with our legal obligations. How long we retain Personal Information will depend on a number of factors, such as the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, our purpose for processing the information, and any legal requirements.

 

9. International users

By using our EP Services, you understand and acknowledge that your Personal Information will be processed and stored in our facilities and servers in the United States and may be disclosed to our service providers and affiliates in other jurisdictions.

Legal Basis for Processing. Our legal bases for processing your Personal Information include:

  • Performance of a contract with you when we provide and maintain our EP Services. When we process Account Information, User Content, and Technical Information solely to provide our EP Services to you, this information is necessary to be able to provide our EP Services. If you do not provide this information, we may not be able to provide our EP Services to you. 

  • Our legitimate interests in protecting our EP Services from abuse, fraud, or security risks, or in developing, improving, or promoting our EP Services, including when we train our models. This may include the processing of Account Information, User Content, Social Information, and Technical Information.

  • Your consent when we ask for your consent to process your Personal Information for a specific purpose that we communicate to you. You have the right to withdraw your consent at any time.

  • Compliance with our legal obligations when we use your Personal Information to comply with applicable law or when we protect our or our affiliates’, users’, or third parties’ rights, safety, and property.

Data Transfers. Where required, we will use appropriate safeguards for transferring Personal Information outside of certain countries. We will only transfer Personal Information pursuant to a legally valid transfer mechanism.

Data Protection Officer. You can contact our data protection officer at team@medprepai.com in matters related to Personal Information processing.

 

10. Changes to the privacy policy

We may update this Privacy Policy from time to time. When we do, we will post an updated version on this page, unless another type of notice is required by applicable law.

 

11. How to contact us

Please contact us if you have any questions or concerns not already addressed in this Privacy Policy.

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